Compliance Standards and Procedures

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APPENDIX 3-G: General Checklist for Global Code Implementation

Regardless of the approach that organizations select to distribute the code, there are a number of steps to consider. Below is a checklist of tips that all companies can follow before and during code introduction to employees around the world.

To DoAction ItemNotes
Before Code Introduction
Discuss the rollout plan with an international advisory group or international management to avoid cultural faux pas that could undermine the initiative. The code rollout should be appropriate for all employees. The international advisory group or international management can help to identify messages, approaches, and language to which international employees might not be receptive. Managers can identify any images or language in the code presentation that might not be appropriate for an international audience.
Be creative when developing messages regarding the code. Organizations may need to overcome the perception that this is “just another initiative from or corporate headquarters,” that can be quickly forgotten.

Determine whether the company will require employees to sign a form acknowledging acceptance of the code’s standards. Code acknowledgement forms are certificates that employees sign indicating that they have read the company’s code of conduct and that they will abide by it. Such forms are standard among U.S.-based companies who undertake such a policy to protect the organization from liability. Some companies also use these forms as a tracking mechanism to ensure that the code is being distributed.

It is important to be aware that such a policy may not be well perceived by international employees, who may view it as an overly legalistic approach. In addition, in many European countries, companies will need to negotiate such procedures with unions and/or works councils, and in certain countries, this will require an amendment as part of employment contracts. It is important to consult local representatives for more information on whether such a practice needs to be implemented.

Consider distributing the code documents to external stakeholders. In today’s global economy, supplier networks play an integral role in companies’ operations. Various scandals have resulted in heightened scrutiny on supply chain management, and stakeholders and the media are holding companies increasingly accountable for the actions of their suppliers. As a result, more and more multinational companies are requesting suppliers to adopt their codes or a supplier version of the code.

During Code Rollout
Distribute the code (or appropriate version of the code) to ALL employees regardless of location or level. It is important to emphasize that all employees—including senior management and the board of directors—share responsibility for ethical behavior. Distributing the code to all employees sends the message that all are accountable for maintaining the standards in the code. Some companies develop a more tailored version of the code to distribute to line workers that addresses the issues that are most relevant to this group; in such a situation, a tailored code would only be circulated to the target audience.
Explain the relevance of the code to all employees and describe the role of the code in relation to other resources available to employees. In certain regions of the world where codes of conduct are not well known or understood, explaining the relevance of the code will assist in conveying the importance of the document.
Familiarize employees with the layout and structure of code. The code should be clearly structured and employees should receive instruction on how to locate information in the document.
Reaffirm—in word and deed—the company’s commitment to responsible business practices and demonstrate the importance of the document to the company’s business. During the process of introducing the code, providing examples to employees of how the company is holding employees accountable for code standards is one way to exhibit the company’s commitment. Companies can also consider recognizing employees for responsible decision-making to illustrate the importance of the code in day-to-day business.
Offer employees an opportunity to ask questions about the code. Many employees around the world will have questions regarding the code. During code rollout, managers need to be equipped to answer questions as they arise. Should managers receive a question to which they do not know the answer, they should not guess. Instead, they should direct such questions to the Ethics and Compliance Office, Legal Department, or Human Resources Department for clarification. Once the managers receive answers, they should follow-up with the employees. This type of follow-up conveys that employee concerns are valued.
Let all employees know that they will receive business standards training that will cover, in part, the important information contained in the code document; however, encourage them to read the code document as soon as possible so that they understand company standards. Indicating that the code will be accompanied by training will put the code in context for employees (i.e., that the code is part of a larger business initiative that the company is spearheading). However, insisting that employees read the code when it is released conveys the significance of the document.
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